Corrective Action Plans

Finding 308688 (2022-068)

Material Weakness 2022

State of Colorado

CO

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.1 § 200.38 § 200.510

(A) CDHS agrees to enhance internal controls over monthly P-EBT reporting to better ensure accuracy. P-EBT is a new program derived from pandemic funding. Being a new program with a lack of federal guidance at implementation, and urgency to get the funds disbursed program staff had to learn about th...

(A) CDHS agrees to enhance internal controls over monthly P-EBT reporting to better ensure accuracy. P-EBT is a new program derived from pandemic funding. Being a new program with a lack of federal guidance at implementation, and urgency to get the funds disbursed program staff had to learn about the nuances of the program and the reporting requirements as it was being implemented. During implementation we recognized that there are some inherent differences with P-EBT from other benefit programs which caused processes to have to be adjusted slightly. Additionally, timing of federal report filing for the P-EBT program is not in synch with our other processes and associated federal reporting requirements and deadlines. This makes it impossible to ensure reconciliation procedures are performed before filing occurs, which is one of our typical internal controls. As a compensating internal control CDHS will ensure that supervisory review processes are performed over P-EBT reporting, and that P-EBT reporting is reconciled to other sources (CBMS and CFMS) as soon as possible after reporting is available. If changes are discovered CDHS will make adjustments to filed P-EBT reports as needed based on reconciliation findings, and communicate changes to necessary parties. (B) CDHS will work to ensure better coordination between program activities and the accounting section relating to federal reporting changes. Accounting will iterate the importance of timely informing the accounting staff when changes are made to program filed federal reports. This message will be delivered in periodic fiscal meetings and identified on the closing calendar. The P-EBT program will ensure that corrections are communicated to accounting on any updates completed on the FNS-292-B report upon discovery, and no later than 30 days after the reporting period. (C) CDHS will ensure that review and approval processes are occurring as designed at various points in the process leading up to entry into CORE. As part of the Requisition (RQS) approval process program and accounting staff independently approve that the correct direct or subrecipient object code is used. These approved RQS transactions are then transitioned into encumbrance documents that drive which object code future expenditures will be booked to. For CCDF transactions related to this finding, both the OEC and Accounting teams inadvertently approved an incorrect object code in 4 RQS's. Staffing shortages coupled with a large increase in workload related to pandemic funding contributed to this oversight. To correct OEC and Accounting will train new staff, periodically familiarize themselves with the appropriate object codes, and perform quality assurance review over object codes before applying approval in CORE. The K1 is compiled from balances derived from expenditure data recorded in CORE. The compilation of the K1 relies on the fact that expenditure balances are accurate, and that prior reviews and approvals of individual transactions have occurred as designed. The K1 currently goes through various levels of review focusing on balance level validation coupled with analytical procedures. To enhance the review process, CDHS will ensure analytical procedures include line level expenditure comparison at the direct and subrecipient levels.

View Audit 282464

Finding 307923 (2022-001)

Significant Deficiency 2022

City of Riverside

CA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

February 2, 2023 Cognizant or Oversight Agency for Audit The City of Riverside respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Lance, Soll & Lunghard, LLP 203 N. Brea Blvd, Suite 203 Brea, CA 9282...

February 2, 2023 Cognizant or Oversight Agency for Audit The City of Riverside respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Lance, Soll & Lunghard, LLP 203 N. Brea Blvd, Suite 203 Brea, CA 92821 Audit period: 07/01/2021 to 06/30/2022 The findings from the June 30, 2022, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. 2022-001 ? Significant Deficiency and Compliance Finding: Timeliness of Payments made to Subrecipients Federal Award Information Federal agencies: U.S. Department of Housing and Urban Development Program Title: Emergency Solutions Grant Program Award Numbers: E-20-MW-06-0538 and E-21-MC-06-0538 Award Years: 2021-2022 Criteria: The U.S. Department of Housing and Urban Development (HUD) requires that payments to subrecipients for allowable costs be made within 30 days after receiving the subrecipient?s complete payment request. Condition: The City did not comply with the 30-day time period requirement for two of its subrecipients since payments to subrecipients for allowable costs were issued 42 days and 46 days after the City received the payment requests. The City has a total of five subrecipients for the program. Cause of Condition: Per inquiry with the Housing Authority Manager, the invoices were not submitted within the required timeframe because purchase orders had to be created before payment to the subrecipient could be processed. Effect or Potential Effect of Condition: The creation of purchase orders prior to the payments to subrecipients being issued led to some delays in the issuance of the payment. Questioned Costs: None. Context: For the year being audited, the payments that were late were the first payment to these subrecipients since no other payment request related to the program appear to have been submitted late. Repeat Finding: No. Recommendation: We recommend that the City implement a process to ensure that payments to subrecipients be issued within the 30-day time period as required by the Compliance supplement. Management?s Response and Corrective Action: The City is taking corrective action to ensure that purchase requisitions are completed timely and proactive communication from the originating department on the status of purchase orders is provided more frequently to ensure that vendors are paid within 30 days after receiving the subrecipient?s complete payment request. The name of the contact person responsible for the corrective action: Michelle Davis. The anticipated completion date for the corrective action: February 28,2023. If the Cognizant or Oversight Agency for Audit has questions regarding this corrective action plan, please contact Nancy Garcia, Controller, ngarcia@riversideca.gov.

View Audit 282250

Finding 301075 (2022-076)

Material Weakness 2022

State of Colorado

CO

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

(A) The Department will update the policy to clarify the frequency in which the risk assessment is required to be completed or updated as applicable for contracts that span multiple fiscal years, as well as identifying exceptions, outlining when it is acceptable to forgo risk assessments. The Depart...

(A) The Department will update the policy to clarify the frequency in which the risk assessment is required to be completed or updated as applicable for contracts that span multiple fiscal years, as well as identifying exceptions, outlining when it is acceptable to forgo risk assessments. The Department will also update the policy to address the nature in which the subrecipient programmatic and financial reports are reviewed. The updates will be completed by November 2023. (B) The Department will provide training on the subrecipient monitoring policy manual to outline roles, responsibilities and the frequency of risk assessments that span over multiple fiscal years. The training will also provide guidance on the programmatic and financial information review process.

View Audit 282464

Finding 301049 (2022-042)

Significant Deficiency 2022

State of Colorado

CO

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.1 § 200.303

(A) We agree with this recommendation. In recent years, the Federal Government had multiple continuing resolutions in their budget process, resulting in CDE?s Title I allocations coming in multiple iterations. For the last several years, CDE has received revised allocations from the US Department of...

(A) We agree with this recommendation. In recent years, the Federal Government had multiple continuing resolutions in their budget process, resulting in CDE?s Title I allocations coming in multiple iterations. For the last several years, CDE has received revised allocations from the US Department of Education for the fiscal year as late as early summer; in one example, we received six revisions. With staffing shortages and the administrative burden to continuously revise, research issues and update FFATA for each allocation change, CDE took the step to report only the final allocation to FFATA, which was reported as of the month the awardee was awarded. However, the report was submitted later in the fiscal year. CDE will take a two-fold approach to rectify the issue related to the required FFATA reporting for Title I. First, we will report to FSRS the initial awards within 30 days following the date the awardee was provided final approval on their award. This is consistent with CDE?s approach to all other federal awards. Second, we will monitor the continuing resolutions and changes in allocations, and report only the net changes to each awardee, in the month those changes occur from the US Department of Education. Thereby, FSRS will represent the total revised award. In addition to this approach, all Title I awards will continue to be a part of our regular FFATA reconciliation process. (B) We agree with this recommendation. CDE identified its own failure to report two ESSER subawards to FFATA within 30 days as part of the successful development and implementation of a FFATA-specific reconciliation process in Summer 2022. CDE will continue to refine and improve its FFATA reconciliation process.

View Audit 282464

Finding 291592 (2022-070)

Material Weakness 2022

State of Colorado

CO

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

(A) The Department agrees with this finding. The Department is moving all adjudication and investigation of program integrity holds into the MyUI+ system, so there will be one system of record. The Department will ensure that all program integrity holds have all documentation through adjudication an...

(A) The Department agrees with this finding. The Department is moving all adjudication and investigation of program integrity holds into the MyUI+ system, so there will be one system of record. The Department will ensure that all program integrity holds have all documentation through adjudication and investigation, including log notes. The Department anticipates this to be fully implemented by July 2024. (B) The Department agrees with this finding. The department has modified processes to ensure all holds are only routed to the appropriate team to be adjudicated. In addition the Department is working to have all claims identified as fraud delivered in a workflow process in MyUI+ rather than the various processes in place now. Further the department is working with our MyUI+ system experts to implement new technology to strengthen and streamline the fraud indicator escalation process and systems within MyUI+. In working with our MyUI+ system experts, the Department anticipates this to be fully implemented by July 2024. (C) The Department agrees with this finding. The Department will continue strengthening security in this area and internal procedures to periodically monitor the potential for internal fraud activities. Additionally, the Department will periodically monitor and review My UI+ access levels for appropriateness. In consultation with our MyUI+ systems experts, the Department anticipates this finding to be fully implemented by July 2024. (D) The Department agrees with this finding. The Department will reinforce and strengthen the ethics policies in yearly communication to staff and tighten escalation policies to ensure pressures and inappropriate requests are handled in accordance with guidelines. The Department anticipates this will be completed by July 2023. (E) When a PI hold is identified as being highly suspicious for criminally fraudulent activity, it is routed to a specialized unit for review, thereby leaving the standard adjudication process. This is handled by passing the review to the UI Investigations and/or Criminal Enforcement (ICE) unit. The investigator performs their investigation and if no actual fraudulent activity is found they will release the hold. The UI Division also performs several quality control reviews of claims and claim decisions via Benefits Payment Control (BPC), Benefits Accuracy Measurements (BAM), Benefits Timeliness and Quality (BTQ), and internal Quality Assurance (QA) reviews. Claims are reviewed for such criteria as adequate support documentation, benefit payment accuracy, timely processing, and correct claim decision determination on all program integrity holds. The Green Book states in Section 10.14, ? If segregation of duties is not practical within an operational process because of limited personnel or other factors, management designs alternative control activities to address the risk of fraud, waste, or abuse in the operational process.? CDLE believes the reviews represent adequate and sufficient compensating controls for the need for segregation of duties on fraud holds. Changing the current process would hinder our ability to deliver UI benefit services timely to our customers and would put us in jeopardy of fulfilling our federal and state payment timeliness requirements.

View Audit 282464

Finding 291585 (2022-071)

Material Weakness 2022

State of Colorado

CO

Subrecipient Monitoring Reporting § 200.1

By the implementation date, the Department of Labor and Employment (CDLE) will complete a review of grant agreements for reporting requirements, including the Federal Funding Accountability and Transparency Act of 2006. By the implementation date, the CDLE will develop and implement appropriate cont...

By the implementation date, the Department of Labor and Employment (CDLE) will complete a review of grant agreements for reporting requirements, including the Federal Funding Accountability and Transparency Act of 2006. By the implementation date, the CDLE will develop and implement appropriate controls and processes to come into compliance with the reporting requirements and submit FFATA reports for the 10 entities identified in the audit.

View Audit 282464

Finding 291415 (2022-066)

Significant Deficiency 2022

State of Colorado

CO

Subrecipient Monitoring § 200.1 § 200.331

Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective actio...

Management agrees with the recommendation. Due to hiring of new staff and an internal audit with similar findings, these actions were in process and implemented as of November 2022. These actions are part of the Sub Team?s standard operating processes and will continue. The proposed corrective action plan is as follows: - The hiring of new team members in 2022; all team members trained on subcontracting processes and documentation requirements with an emphasis on following standard baseline procedures. - New Subcontract Administrator (SCA) position tasked with compiling final packets for each sub, which includes a quality check to ensure all documents and signatures required are included. - Use of subcontract checklist and risk assessments required and consistently done by the team.

View Audit 282464

Finding 286713 (2022-079)

Material Weakness 2022

State of Colorado

CO

Subrecipient Monitoring Reporting § 200.303 § 200.332 § 200.501

The Department of the Treasury (Treasury) strengthened its internal controls with DOLA?s agreement to disseminate the necessary information to the subrecipients in compliance with federal requirements for subrecipient monitoring and reporting for the Minerals Leasing Act program (Program) at the ear...

The Department of the Treasury (Treasury) strengthened its internal controls with DOLA?s agreement to disseminate the necessary information to the subrecipients in compliance with federal requirements for subrecipient monitoring and reporting for the Minerals Leasing Act program (Program) at the earliest possible opportunity following receipt of the recommendation in the previous FYE?s report as the monitoring and reporting for the Program could only be performed following the annual distribution of such funds which took place subsequent to FYE 2022. The Department will formalize an Interagency Agreement with DOLA and any other relevant parties, incorporating additional corrective action before the stated date above (June 30, 2023).

View Audit 282464

Finding 286696 (2022-063)

Significant Deficiency 2022

State of Colorado

CO

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303 § 200.334

In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission proc...

In December 2022, the Office of Financial Aid strengthened its internal control over the reporting requirements for the Higher Education Emergency Relief Fund (HEERF), by adding the report due dates to the internal operational calendar. Additional level reviews were also added to the submission process before the required reports will be sent to the Department of Education and posted on the financial aid website.

View Audit 282464

Finding 279102 (2022-002)

None 2022

Greater Cleveland Food Bank

OH

Questioned Costs Subrecipient Monitoring Reporting

Finding: 2022-002 Internal Control over Compliance with Reporting Agency: Greater Cleveland Food Bank Name of responsible contact person and title: Jessica Morgan, CPO & Valissa Turner Howard, VP of Talent and Legal Affairs Anticipated completion date: 7/31/2023 Agency's response: Concur Planned Cor...

Finding: 2022-002 Internal Control over Compliance with Reporting Agency: Greater Cleveland Food Bank Name of responsible contact person and title: Jessica Morgan, CPO & Valissa Turner Howard, VP of Talent and Legal Affairs Anticipated completion date: 7/31/2023 Agency's response: Concur Planned Corrective Action(s): ? The Agency Services Analyst will complete the quarterly report within 35 days of the end of the quarter to ensure proper review, approval, and corrections if necessary, in order to be submitted within the 45-day requirement. Prior to the report being submitted, the Director of Agency Services will continue to review and will provide oversight for timely submission. ? Include in our Internal Auditing Program of the OAF/TANF contract, review of all supporting documents to validate timely reporting. ? The VP of Talent and Legal Affairs with the support of the Compliance Manager will review the timelines for all required reporting to the Ohio Association of Food banks on an annual basis with supervisors and those employees responsible for reporting.

View Audit 264352

Finding 279096 (2022-001)

Material Weakness 2022

Greater Cleveland Food Bank

OH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: 2022-001 Internal Control over Compliance with Activities Allowed or Unallowable Agency: Greater Cleveland Food Bank Name of responsible contact person and title: Jessica Morgan, Chief Programs Officer and Dwayne Brake, VP of Operations Anticipated completion date: 7/31/2023 Agency's respon...

Finding: 2022-001 Internal Control over Compliance with Activities Allowed or Unallowable Agency: Greater Cleveland Food Bank Name of responsible contact person and title: Jessica Morgan, Chief Programs Officer and Dwayne Brake, VP of Operations Anticipated completion date: 7/31/2023 Agency's response: Concur Planned Corrective Action(s): ? Reimplementation of pre-COVID delivery and rece iving practices, signed receipts, regarding all food and commodities to sub-recipient agencies. ? Include a review of all supporting documents and signed receipts in our Internal Auditing Program of the TEFAP contract. ? Staff who are responsible for collecting invoice signatures, including the responsible parties, will be retrained on the procedure and will annually review the requirements for signed receipts for government commodities to ensure proper record keeping.

View Audit 264352

Finding 265183 (2022-003)

Material Weakness 2022

Overdose Lifeline, Inc.

IN

Questioned Costs Period of Performance Subrecipient Monitoring

Finding 2022-03 Expenditure of Funds Outside Contract Period Condition: In the course of testing direct disbursements for adherence to appropriate cutoffs concerning the contract's period of performance, it was discovered that the Organization incurred a substantial amount of expenditures on contr...

Finding 2022-03 Expenditure of Funds Outside Contract Period Condition: In the course of testing direct disbursements for adherence to appropriate cutoffs concerning the contract's period of performance, it was discovered that the Organization incurred a substantial amount of expenditures on contracts prior to the official contract start date. These disbursements took place without acquiring proper authorization for making disbursements prior to the contract's commencement. Despite the unique nature of Naloxone inventory being treated as a prepaid asset due to its delayed usage, the majority, if not all, of the Naloxone units were fully expended before the contract officially commenced. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the CEO and the COO acknowledge the finding of expending funds outside the contract period. This finding is connected to the purchase of the emergency medication naloxone. The Organization decided to purchase with no assurance of reimbursement in order to eliminate the lack of emergency medication in an overdose epidemic. The Organization had verbal approval but did not secure approval in writing. Numerous policies will be adopted in 2023 to ensure this does not occur again. Some of these policies include the transition to an experienced nonprofit bookkeeper, training for Finance and Grants Management and tracking mechanisms, monthly grants tracking meetings to ensure inventory and spending, and the adoption of a clear and documented approval process should spending, outside a contract period, be required.

View Audit 261078 Questioned Costs: $1

Finding 265160 (2022-001)

Significant Deficiency 2022

Sewall Child Development Center INC

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

CORRECTIVE ACTION PLAN Finding 2022-001 Information on the Federal Program: Assistance Listing Number 93.600-Head Start Program, United States Department of Health and Human Services. Pass- Through Entity: the City and County of Denver and Mile High Early Learning. Award Number: MOEAI202158316, MO...

CORRECTIVE ACTION PLAN Finding 2022-001 Information on the Federal Program: Assistance Listing Number 93.600-Head Start Program, United States Department of Health and Human Services. Pass- Through Entity: the City and County of Denver and Mile High Early Learning. Award Number: MOEAI202158316, MOEAI-202158627, 08HP000174-03. Compliance Requirements: Allowable Costs Type of Finding: Material Noncompliance and Significant Deficiency Planned Corrective Action: Management at Sewall Child Development Center has been relying on a manual system of time tracking across our programs. Given the complexities of our various blended funding sources, we agree that we need an improved tracking system with better automation of payroll and the time tracking process. This is especially true with the demands on our staff with the coordination of multiple grants. The review of automated systems is in process. Name of Contact Person: Heidi Heissenbuttel, CEO/President Anticipated Completion Date: We anticipate doing a review of payroll companies by May 2023 to have a new system in place by the new fiscal year, July 2023. Meanwhile, there will be greater supervision of time sheet allocations, implemented immediately.

View Audit 261075

Finding 264817 (2022-006)

None 2022

Elysian School

MT

Subrecipient Monitoring Matching / Level of Effort / Earmarking

WAGE RATE REQUIREMENTS Name of contact person: Laurie Hickethier Corrective Action: In the future, the District will put steps in place to ensure all projects funded with federal money that will be over the $2,000 limit will require the company hired to supply the district business manager with a ...

WAGE RATE REQUIREMENTS Name of contact person: Laurie Hickethier Corrective Action: In the future, the District will put steps in place to ensure all projects funded with federal money that will be over the $2,000 limit will require the company hired to supply the district business manager with a certified copy of their payroll for the job done. The district business manager will verify that the wages paid are for the contract no less than the locally prevailing wage for the corresponding work on similar projects in the area. Proposed Completion Date: Immediately

View Audit 262547

Finding 254952 (2022-005)

Significant Deficiency 2022

Healthcare for the Homeless - Houston

TX

Subrecipient Monitoring Cash Management Reporting

Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviewed draws on federal funds noting no discrepancies. Going forward, the Chief Financial Officer will calculate the amount of the draw on federal funds, which will then be rev...

Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviewed draws on federal funds noting no discrepancies. Going forward, the Chief Financial Officer will calculate the amount of the draw on federal funds, which will then be reviewed, approved, and documented by the Chief Executive Officer before the draw is submitted. Anticipated correction date: This has already been implemented retroactively effective January 2023. Responsible official: Gabriela Cordero, Chief Financial Officer.

View Audit 235553

Finding 252559 (2022-001)

Significant Deficiency 2022

United Food Bank

AZ

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.303

2022-001 U.S. Department of Agriculture, Food, and Nutrition Service Emergency Food Assistance Program CFDA Number: 10.568/10.569 Passed Through: The Arizona Department of Economic Security Pass Through Number: CtR052634 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding ? Significant Defi...

2022-001 U.S. Department of Agriculture, Food, and Nutrition Service Emergency Food Assistance Program CFDA Number: 10.568/10.569 Passed Through: The Arizona Department of Economic Security Pass Through Number: CtR052634 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding ? Significant Deficiency in Internal Control over Compliance Condition/Context ? Internal control procedures over eligibility requirements for 1 of 40 eligibility sheets tested indicated there was no certifying signature by the eligible recipient agency volunteer, and there was no evidence of secondary review by the distribution agency program officials. Contact Person ? Chariti Stern, Chief Program Officer Corrective Action Plan ? United Food Bank has entirely onboarded all TEFAP agencies to be active on Link2Feed; however, a handful of agencies still use sign-in sheets due to technology limitations. At the 2022 Agency Conference, a presentation was done that conveyed the importance of checking all signatures on United Food Bank documents. The 2022 Partner Agency Handbook explains that a signature is required for the reports and sign-in sheets to be authorized and accepted by United Food Bank. Re-training United Food Bank staff has also occurred to ensure that all reports have the correct signatures and that the United Food Bank staff?s initials are on all documents to ensure that the reports were reviewed.

View Audit 257571

Finding 238658 (2022-001)

Significant Deficiency 2022

Housing Authority of the City of Greensboro

NC

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding 2022-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Significant Deficiency Corrective Action Plan: GHA will implement the following immediate and on-going actions to correct internal control over particip...

Finding 2022-001 - Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Significant Deficiency Corrective Action Plan: GHA will implement the following immediate and on-going actions to correct internal control over participant files in the Housing Choice Voucher program: Immediate Response: GHA is guided by seven core values. The first of which is Integrity. Upon discovery of forged documents, in March 2023 it was clearly communicated and reiterated that any actions, such as alternation, falsification, or fabrication is unacceptable and the appropriate disciplinary would be taken. A prompt and thorough investigation resulted in a team member being terminated for forging documents and a change is senior leadership. A third-party consultant was brought in immediately to complete an assessment and review of the voucher programs internal process to provide immediate process improvement along with reviewing an additional sample set of participant files. Ongoing Response: GHA will improve internal controls in the area of file review and quality control and assurance by completing multiple examinations of applicants/program participants calculations at initial move- in, interim, and re-examination anniversary. In addition to the two-prong reviews being completed by team members, a third-party compliance company may be used to review all initials, and up to twenty-five percent (25%) of all interim and re-examination of program participants' files. Internal/external training will be provided to each team member involved with the determination of rent and maintaining tenant files, as well as programmatic eligibility and administration of the housing choice voucher program in 2023. Voucher Administration leadership will continue to work closely with the Compliance Department to ensure that GHA's program files are compliant with all federal regulations, rules, HUD guidelines as well as GHA's policy and procedures. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of December 2023. Responsible Person: Meredith Daye, Chief Operating Officer

View Audit 254659

Finding 236256 (2022-001)

Significant Deficiency 2022

Easter Seals Southeast Wisconsin, INC

WI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.236 § 200.318

Easterseals Southeast Wisconsin has a policy which clearly outlines approval authorities. While we follow that policy properly, we understand that the policy lacks some elements required by the Uniform Guidance. None of our purchases made during the year under audit would have violated Uniform Guida...

Easterseals Southeast Wisconsin has a policy which clearly outlines approval authorities. While we follow that policy properly, we understand that the policy lacks some elements required by the Uniform Guidance. None of our purchases made during the year under audit would have violated Uniform Guidance, but we are committed to compliance and therefore have already started to draft policies which will adhere to Uniform Guidance. We will finalize, communicate, and follow our updated Policies and Procedures to ensure that Uniform Guidance is followed and to resolve the finding from this audit.

View Audit 257573

Finding 230248 (2022-001)

Material Weakness 2022

Northeast Ohio Medical University

OH

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding Number: 2022-001 Anticipated Completion Date: 07/19/2022 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Planned Corrective Action: Ensure all graduation dates are reported on enrollment reporting within ...

Finding Number: 2022-001 Anticipated Completion Date: 07/19/2022 Responsible Contact Person: Katherine Miranda, University Registrar Kelly Burt, Assistant Registrar Records Management and Reporting Planned Corrective Action: Ensure all graduation dates are reported on enrollment reporting within 30 days of the status change Due to new procedures, reporting processes and new staff, a group of our Spring 2022 graduates were not reported in a timely manner. Once we were made aware of this issue, we went into immediate action to correct the error. We worked with Clearinghouse to confirm our own misconceptions and ways to remedy the error. We updated all records individually through the Clearinghouse system. After all records were corrected, we updated our staff manual to ensure this does not occur in the future. Staff will continue to review all records to ensure accurate and timely reporting.

View Audit 252913

Finding 212944 (2022-011)

None 2022

Park County

MT

Procurement, Suspension & Debarment Subrecipient Monitoring

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30 2022 Name of contact person: Director of Grants and Special Projects Corrective Action: The county will develop written procedures as recommende...

NONCOMPLIANCE WITH PROCUREMENT, SUSPENSION & DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS; AL No. 21.027, YEAR ENDED JUNE 30 2022 Name of contact person: Director of Grants and Special Projects Corrective Action: The county will develop written procedures as recommended in finding 2022-007 to address this issue and incorporate this finding?s recommendation. Proposed Completion Date: Immediately

View Audit 250852

Finding 205955 (2022-001)

Material Weakness 2022

Great Hearts America - Texas

TX

Questioned Costs Subrecipient Monitoring Material Weakness § 200.302

Finding 2022-001 - Schedule of Expenditures of Federal Awards United States Department of Education Pass Through Entity: Texas Education Agency Federal Program: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425U Federal Award N...

Finding 2022-001 - Schedule of Expenditures of Federal Awards United States Department of Education Pass Through Entity: Texas Education Agency Federal Program: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425U Federal Award Number: S425U210042 Federal Award Year 2022 Repeat Comment: No Type of Finding: Material Weakness Condition: When reviewing the net assets released from restriction in the draft financial statements presented to the board, management determined and brought to the attention of the auditors the net assets restricted for pre-award costs for the ESSER federal program ($1,976,911) should have been released from restrictions during fiscal year ending June 30, 2022. The auditor, when tying the draft schedule of expenditures of federal awards to the updated schedules, determined the Organization had not included the pre-award federal expenditures related to the ESSER federal program. As a result, the initial testing of the ESSER major program did not include $1,976,991 in ESSER expenditures. When this was brought to management?s attention, the schedule of expenditures of federal awards was updated and the additional expenditures provided for testing. Cause: The additional $1,976,991 was related to ?pre-award? dollars awarded during fiscal year ended June 30, 2022, where allowable expenditures incurred in the previous year were permitted by the grant to be used for the ESSER funds awarded in the current year. Management was not aware of the requirement to include these amounts on the schedule of expenditures of federal awards. Recommendation: We recommend management of the Organization strengthen their internal controls to ensure all federal awards are included on the schedule of expenditures of federal awards. Corrective Action Plan: Prior to June 30, 2023, management will prepare an administrative procedure that requires the auditor to provide a draft financial and compliance report at least one (1) week prior to the meeting of the Board. In the procedure, management will require staff to reconcile the Schedule of Expenditures of Federal Awards to the Statement of Activities and other relevant accounting information to ensure the accuracy and completeness of the amounts disclosed. Person Responsible: Kevin Byrne, Vice President of Finance Anticipated Completion Date: June 30, 2023

View Audit 174625

Finding 205954 (2022-002)

Material Weakness 2022

Regional Office of Education #17

IL

Subrecipient Monitoring Reporting

The Regional Office of Education #17 will work with their contracted accounting firm to receive the draft financial statements earlier in order to allow additional review time before they are due for audit.

View Audit 174609

Finding 205950 (2022-001)

None 2022

Pine River Area Schools

MI

Cash Management School Nutrition Programs Subrecipient Monitoring

Corrective Action Plan 2022-001 This finding is caused by the District?s Food Service Fund?s fund balance being over the USDA?s threshold of 3 months average expenditures. The District is fully aware of this situation and has a spend down plan in place to help alleviate the excess fund balance down ...

Corrective Action Plan 2022-001 This finding is caused by the District?s Food Service Fund?s fund balance being over the USDA?s threshold of 3 months average expenditures. The District is fully aware of this situation and has a spend down plan in place to help alleviate the excess fund balance down to a reasonable level and anticipates the completion date for the corrective action plan be before the end of the 2022-23 fiscal year. The person responsible for the corrective action is Michelle Adams, the food service director. The plan for monitoring adherence is the food service director will work to assess where the fund balance is after all of the projects from the spend down plan are completed.

View Audit 174605

Finding 204814 (2022-001)

Material Weakness 2022

YWCA Northeast Indiana, Inc.

IN

Reporting Subrecipient Monitoring

2022-001- Schedule of Expenditures of Federal Awards Management acknowledges the recommendation and will develop internal controls over reporting and consult with external consultants if necessary to ensure an accurate SEFA is prepared. It is anticipated that the implementation of the controls...

2022-001- Schedule of Expenditures of Federal Awards Management acknowledges the recommendation and will develop internal controls over reporting and consult with external consultants if necessary to ensure an accurate SEFA is prepared. It is anticipated that the implementation of the controls will be completed by year end, December 31, 2023 and will be put in place at that time. Greg Johnson, CFO YWCA Northeast Indiana

View Audit 174138

Finding 199937 (2022-022)

Significant Deficiency 2022

Ser-Jobs for Progress of the Texas Gulf Coast, Inc. and Subsidiary

TX

Questioned Costs Subrecipient Monitoring Reporting

Finding No. 2022-002 - NON-COMPLIANCE AND SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER NONCOMPLIANCE WITH REPORTING REQUIREMENTS Planned Corrective Action: SER-Jobs has registered with Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and reported the subawar...

Finding No. 2022-002 - NON-COMPLIANCE AND SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER NONCOMPLIANCE WITH REPORTING REQUIREMENTS Planned Corrective Action: SER-Jobs has registered with Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and reported the subaward data through FSRS and is now in compliance with the requirements of the Federal Funding Accountability and Transparency Act requirements. In addition to becoming compliant, SER-Job's procedures, related to the submission of all reporting requirements, including supplemental requirements not required or collected by the awarding agency, have been expanded to include seeking additional guidance from external sources, such as our external auditors. These external sources, will possess the knowledge and expertise to assure that SER-Jobs follows all reporting requirements, including supplemental requirements originally unknown to SER-Jobs and not communicated by the awarding agency. Anticipated Completion Date: March 1, 2023 SER-Jobs Contact Person Responsible for Corrective Action: Mr. Gerald Eaton, CFO

View Audit 250048

Corrective Action Plans

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